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Valenton, Francis Angelo T.

Criminal Law 2


People vs. Genoves (G.R. No. L-42819)

Facts: The plaintiff-appellee is the People of the Philippines. The defendant-appellant is Crispin
Genoves. In the case at bar, on May 28, 1934, the appellant and the deceased Soledad Rivera
were laborers in adjoining cane fields. The latter claims that the yoke of plow which the herein
was repairing, belonged to her and tried to take it by force. It caused the appellant to struck her
with his fist, causing her to fall to the ground. As she got up, the appellant then punched her on
the left cheek of Soledad causing her again to fall to the ground. After the incident, Soledad
proceeded to the municipal building and complained to the police for maltreatment. Almost two
weeks after the incident, such hemorrhage caused to Soledad caused the painful and difficult
premature delivery of one of the twin babies she was carrying. Both were delivered, but both
were dead. Later on. Soledad died. The Court of First Instance of Occidental Negros of the
complex crime of homicide with abortion.

Issue: Is the appellant liable for said crime.

Held: The Supreme Court said that the abortion in this case was clearly unintentional as
penalized by Article 257 of the Revised Penal Code. The CFI Occidental Negros was wrong in
holding him liable of the complex crime of homicide with abortion.